Hi Thomas,

There’s no law that mandates holiday pay at all.
So you can set up whatever policy you like.

However, you’re inviting a discrimination lawsuit if you provide employees in one location with holiday pay and not in another. Here’s why. Let’s say the location you provide holiday pay in has more males or whites (or any variable) than another location where employees don’t get paid holiday pay. The ones not getting that pay could sue you for discrimination (age, gender, sexual orientation?) if they feel that’s the reason you’re not giving them holiday pay.

The judge will then ask, “what do you do in your other locations?” That’s where you’re likely to run into trouble.

So legally, you can do what you like, but be careful that employees understand your non-discriminatory rationale for having a more generous policy in one location than another.

Best!

Laura

https://fitsmallbusiness.com/floating-holiday-policy/
https://fitsmallbusiness.com/holiday-pay-policy/